A Few Responses

FDA’s response to the Chapman University Study finding 38% of pet foods tested possibly mislabeled, a brief response from the publisher of the Chapman University Study, a response from FDA regarding rancid fat pet food test results linked to the death of 12 animals and a response from Purina and FDA regarding their new product making ‘human grade ingredient claim’.

Chapman University’s study found that 38% of the pet foods they tested contained a meat ingredient not listed on the label or did not contain a meat ingredient that was promised to be included in the pet food. The following questions were sent to FDA regarding this alarming university study…

What assurance can FDA provide consumers their pets are safe from eating mislabeled foods? What action will FDA take to protect pet food consumers from pet food fraud? Can FDA provide consumers with assurance pets are not at risk to a PED type virus that could spread to cats and dogs?

PEDv is transmittable only among pigs and cannot be transmitted to other animals or human beings.

Response (not sent to FDA): It appears the FDA is saying they can take action, FDA has the authority – but in this case they are not going to do a thing. FDA provides “a recent warning letter issued for this violation” seeming to imply the agency has recently investigated pet food fraud. The FDA warning letter turns out to be Evangers Pet Food from back in 2011 – three years ago. Since that FDA investigation – two studies have been published finding numerous instances of pet food fraud. The 2012 ELISA Technologies study finding almost 50% of foods tested were mislabeled due to an undeclared meat protein or lack of meat protein listed on the label. And the 2014 Chapman University study finding 38% of foods tested were mislabeled due to the same circumstances.

It is clear the pet food industry has a problem with mislabeling. What a shame the FDA doesn’t recognize the problem and take action to protect pet food consumers. I hope the FDA reconsiders.

Questions were sent to Dr. Rosalee Hellberg the publisher of the Chapman University study asking if the University had plans to release the names of the foods tested and if they tested the unidentified meat proteins for dog or cat DNA. Her response…

Thank you for your interest in the pet food study. In response to your question, we did not test the nonspecific meat ingredient for dog or cat DNA. There are a variety of other meat species that could have been present and we limited our testing to the species named in the study. Also, it was not our intention to single out pet food brands, but rather to investigate the issue as a whole. Therefore, we will not be releasing the names of the brands that were found to be potentially mislabeled.

A few weeks ago, TruthaboutPetFood.com shared a heartbreaking story of the death of 12 animals (7 dogs, 5 pigs) who consumed a Pedigree dog food. The consumer reported the food and the animal deaths to FDA and to Texas authorities – no one investigated. In numerous back and forth emails with FDA, I finally received a statement from the agency. The FDA shared they did not show a report was filed on this dog food and asked that the incident be reported (again). I continued to push for a response from FDA to the lab results of the dog food – finding a high level of rancid fat in the food (the consumer had the food tested). FDA finally told me…

Rancid fat should not be in food and most commonly happens from improper handling or storage of the finished product. FDA has not set action levels for every hazard or contaminant, including rancid fat; however, the agency could take action if rancid fat or rancidity was found during the inspection of an animal food manufacturing facility.

Response (not sent to FDA): Again we have the issue of ‘inspection’. To my knowledge, pet food manufacturing plants are rarely inspected (every ten years or so) unless there is a serious concern found in the food. Such as Salmonella. If a pet food or treat is tested to contain Salmonella, it is common for FDA inspectors to inspect a plant for days (at the expense of the manufacturer). Salmonella could kill a human (that came in contact with the pet food), rancid fat could kill the pet. Both are serious concerns. However it appears that ‘inspection’ is only priority if the food is a risk to humans (not the pets).

And TruthaboutPetFood.com recently reported that a Purina pet food ‘topping’ product makes the claim it is “made with real, human-grade ingredients”. Questions were sent to FDA asking if Purina is being held to the same requirements as some of the smaller pet food manufacturers using human grade ingredient claim.

Background – pet food manufacturers that use human grade (USDA inspected and approved human edible) claims in their advertising or on product labels are forced to obtain what is known as a ‘Letter of No Objection’ from FDA. Individual states are refusing to allow products to be sold within their borders with the human grade claim without the FDA ‘Letter of No Objection’.

Does Purina have this ‘No Objection’ letter from FDA? FDA wouldn’t tell me. I was told I would need to file a Freedom of Information Act request for the information.

Purina stated…

Dear Ms. Thixton,

Thank you for contacting Nestle Purina PetCare Company and for your interest in our new Purina® Pro Plan® – Savor® – Additions™ for Dogs.

To answer your question, Purina is in compliance with the FDA as it relates to the human grade ingredient language used to promote this product. The ingredients we use in this product are fit for human consumption and meet the U.S. regulatory standards for human edible grade ingredients.

Our Purina® Pro Plan® – Savor® – Additions™ for Dogs are produced by a co-manufacturer. Every co-manufacturer of Purina products must meet our strict standards for ingredient specifications, product safety, sanitation and good manufacturing practices.

Again, thank you for contacting us to learn more about our new product.

Response (not sent to FDA or to Purina): In previous experience with Freedom of Information Act (FOIA) requests to FDA, even though it is required by law for the agency to respond within a set time frame, that doesn’t always happen. I’m still waiting on a FOIA request from FDA sent well over a year ago. What a shame they couldn’t just provide the information as an effort in pet food transparency.

And with Purina, though it is a baby step – I find it encouraging that one of the largest manufacturers of pet food in the world is taking a baby step towards a ‘food’ ingredient pet product (versus a ‘feed’ ingredient pet product). Can we expect more pet ‘food’ products from Purina?

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Comment11

Laura
Oct 01, 2014

“Also, it was not our intention to single out pet food brands, but rather to investigate the issue as a whole. Therefore, we will not be releasing the names of the brands that were found to be potentially mislabeled.” That must be code for “We’re too afraid of getting sued or receiving bad press to stand up and help protect pets, so we’re just going to keep throwing the word ‘potentially’ around and act as neutral as possible.”

Hi. I have talked to food reps for Science Diet and they told me that they are allowed to do substitutions in the food as long as it is for less then 6 months without changing the ingredient label. If the substitution is going to be for longer then 6 months then they have to change the ingredient label. Perhaps that would account for the food mislabeling issue.

An example of a completely unacceptable loophole. If a consumer was attempting to avoid certain ingredients, s/he may not in fact be able to do so, since the pet food manufacturer can swap ingredients (generally owing to international sourcing/ cost issues, as part of “least cost mix” protocols), without changing the label. Consumers are reliant on FDA “administration” of the Food Safety Act… but expecting safety isn’t just something we can rely on.

“Also, it was not our intention to single out pet food brands, but rather to investigate the issue as a whole. Therefore, we will not be releasing the names of the brands that were found to be potentially mislabeled.”

So what was the point, Chapman? And even if the FDA *wanted* to take action as a direct result of this testing, how could they if Chapman refuses to release the names of the foods?

This makes me quite angry. I see it as being very irresponsible of them.

That’s exactly what I was trying to say, that it makes everything seem completely pointless. If a kid did a science project in school and didn’t completely disclose the results to their teacher the student probably wouldn’t get a very good score.

Susan, I don’t know how you were able to end your post with an optimistic remark “Can we expect more pet ‘food’ products from Purina?”

Even if purina makes more items using human grade foods, I will not buy anything from them as long as they are still selling ANYTHING that is not decent and safe enough for my pets. This “foray” into actual “food” is just a marketing ploy. I would hope that current purina users will finally realize that if purina has to say this one little product is “human grade” then that should imply that everything else they make is NOT.

So the study of pet foods by the university was just a little science project. I wonder what the students learned from this project? How to further waste tax payer dollars on useless studies after they graduate and join the FDA and other government agencies?

Dr Chapman’s biography answers that question, she interned with the FDA. She cannot show them up as not doing their job. BTW, she only sponsored the study, an undergrad did it (who may have her own motive for not revealing names, including leaving her job options open upon graduation…its a tough job market you know.) (sarcasm intended)
From Chapman’s website:
Dr. Rosalee Hellberg is an Assistant Professor in the Food Science Program at Chapman University. Prior to Chapman University, Dr. Hellberg completed a fellowship program at the U.S. FDA, where she contributed to the development of rapid, DNA-based test methods for organisms such as norovirus, Salmonella, and Listeria. Dr. Hellberg completed an M.S. and Ph.D. in Food Science and Technology at Oregon State University, studying seafood safety and fish species misbranding. She has published 20 peer-reviewed articles and book chapters and given 25 professional presentations.